Ex-situ Treatment & CAMU Implications at the Springvilla Site

Transcription

1 Ex-situ Treatment & CAMU Implications at the Springvilla Site David Anderson, Oregon DEQ State Coalition for Remediation of Drycleaners Kansas City, September 2004

2 Introduction Q Cleanup of former dry cleaning business Development driven schedule Partial building demolition Soil excavation with on-site treatment In situ treatment of remaining/residual source Q Streamlined RCRA process Corrective Action Management Unit (CAMU)

3 Drycleaner RCRA in a Nutshell Q Dry cleaners cleanup subject to RCRA requirements Q Is waste listed? Q Land Disposal Restrictions (LDR)/Universal Treatment Standards (UTS) for PCE F002 and/or Characteristic Unknown use/process and/or knowledge of generation date Wastewaters (Water) mg/l Nonwastewater (Solids) mg/kg If above 10 X UTS then treatment required (60 mg/kg) Q Treatment and/or Disposal at Subtitle C Landfill

4 RCRA cont. Q Good overview document RCRA Management of Remediation Wastes October 1998, EPA 530-F Q Area of Contamination (AOC) Policy Q Contained-in Policy Media no longer contains hazardous waste Q Corrective Action Management Unit (CAMU) Rule allows for on site management and/or treatment of remediation wastes Typically ex-situ treatment and doesn t trigger LDRs Can be considered an ARAR as applied to CERCLA type sites (e.g. Dry Cleaners)

5 CAMU Q Rule amended to allow offsite disposal of certain remediation wastes known as CAMU-eligible wastes Federal Register, January 22, 2002 Q Treat contaminated media to standards For example - Reduction of toxicity or mobility Q Other Items 90% capped by 10X UTS and TCLP for metals Site specific adjusted standards Approval of regulators, permit exemptions Public Notice Requirement Landfill Permit modification

6 Oregon RCRA Q Oregon is RCRA rule authorized Q Oregon has state rule permit exemption authority Also some federal CERCLA provisions Q Oregon DOJ ruling on sites; RCRA Waste F002 and may also be Characteristic Waste

7 Proposed Cleanup Process Q Establish CAMU or Exemption Q Remove/stage contaminated media Q Alternatively direct haul to Subtitle C Landfill Treat media to some standard Compare media levels to Region IX PRGs or State RBCs for residential soil and drinking water Use the contained-out provisions of RCRA Dispose of waste at Subtitle D Landfill As listed hazardous waste As CAMU-eligible waste

8 Soil Target Cleanup Levels Q CAMU Rules Constituent Initial Concentration (Springvilla) UTS under 40 CFR % Removal 10 X UTS Treatment Standard PCE 640 mg/kg 6 mg/kg 64 mg/kg 60 mg/kg 60 mg/kg Q Contained-In Policy Constituent Concentration DEQ RBCs Region IX PRGs PCE - Water 7,100 ug/l 91 ug/l 0.66 ug/l PCE Soil 640 mg/kg 1.1 mg/kg 1.5 mg/kg

9 Springvilla Cleaners Q Former Dry Cleaner Laundromat facility with self serve dry cleaning machines A full service dry cleaner at later date Q Located within a large grocery store Q Within the City of Springfield well field system Q Multiple municipal, industrial, and residential wells.

10 Springvilla Cleaners Q PCE soil contamination from 640 mg/kg to 130 mg/kg at feet bgs (near water table) Q PCE groundwater contamination to 79 mg/l at same location Q Color-Tec screening

11 Site Background

12 Building Demolition

13 Soil Excavation Q Soil excavated to groundwater table Q Approximately 200 cubic yards

14 On Site Soil Venting Q Active stripping with blower Q Off gas treated using vapor phase carbon

15 Source Area Treatment Q In-situ treatment of remaining source Permanganate injection in source area for groundwater contamination Sub-slab venting of vadose zone Active versus Passive Future biostimulation of remaining contamination

16 Source Area Treatment

17 Permanganate Q Potassium permanganate (KMnO 4 ) to promote in situ chemical oxidation 20% solution injected into the infiltration gallery Approximately 2,000 gallons of KMnO 4 Q Relatively cost effective - $1.60-$1.80/lb Q Some issues with natural impurities (Cr 6+ )

18 Springvilla Cleaners Q Biodegradation Future injection of 6,000 lbs of emulsified oil for biodegradation through same infiltration gallery. Confirmation of bug population Possibly add Dehalococcoides ethanogenes microorganisms

19 Costs Comparison Q Disposal Costs Q Projected savings at site Subtitle C, F002 listed soil - $300/ton Subtitle D, Non-listed soil or contained-in - $50/ton Incineration F002 listed carbon - $800/ton Subtitle C, CAMU-eligible carbon - $70/ton Soil = $12,000 versus $84,000 Carbon = $750 versus $2,000 Q Doesn t include possible savings of Hazardous Waste Generator Fees

20 Cost to Implement Site Capital Costs Disposal Monitoring Total Springvilla $40,000 $12,000 $5,000 $57,000

21 Issues Q RCRA issues Degradation products and/or underlying hazardous constituents (UHCs) Is state rule authorized? Q Hidden costs/savings Contractor and laboratory costs may increase Time requirement for permits and public notice Q Logistics Space limitations at dry cleaners Seasonal treatment issues

22 Issues cont. Q Closure sampling and timeframe requirements Composite sampling Q Possible risk exposures from venting operation Q Ecological risks not addressed Q Groundwater Treatment Wastewater treatment plant POTWs Reinjection Q Caveat Emptor, Your Mileage May Vary